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Reward System for Meeting Ethics and Compliance Standards
Where has the value of an individual's morals and integrity gone today? When anyone of us sits down in our comfortable Lazy Boy chair and turns on the evening news we are inundated with numerous negative news events of the day. We have so many stations available to us and as we scan through the channels we notice most news broadcasts are on the negative side. Is this new to us today or has this been going on for generations? These news events range from murder, rape, sex crimes against a minor, theft, and a 'white collar crime'. Most of us know what each of these crimes involves; but, what is a "white collar crime"? "According to the field of criminology, white-collar crime has been defined by Edwin Sutherland as "a crime committed by a person of respectability and high social status in the course of his occupation" (Curtis, 2010)
What are some types of white collar crimes? Some examples, antitrust violations, computer and internet fraud, credit card fraud, phone and telemarketing fraud, bankruptcy fraud, healthcare fraud, environmental law violations, insurance fraud, mail fraud, government fraud, tax evasion, financial fraud, securities fraud, insider trading, bribery, kickbacks, counterfeiting, public corruption, money laundering, embezzlement, economic espionage and trade secret theft. As a result of the growth of white collar crime, additional legislation has been written to attempt to slow down the criminal activity.
A noteworthy piece of crime legislation began with the Interstate Commerce Act in 1887. This act was designed to regulate the railroad industry due to its monopolistic nature. A number of pieces of legislation have been introduced since 1887 each confronting a different type of economic crime. We need to start a movement similar to the "Go Green" movement today which has been developed to encourage recycling paper and glass products. In the same manner a program should be implemented to encourage a reward system for a compliant business which consistently meets and exceeds ethical standards.
'Ethics in Corporate America have taken a setback in recent years. Enron, WorldCom, and Martha Stewart are examples of highly-publicized cases where there was a failure of the corporation to maintain an ethical environment. Whether large or small, profit or not-for-profit, corporations have a responsibility to act ethically". (Ethics in Community Association Operations, 2006) Each business is different and, as such, businesses must tailor their program to address the compliance issues specific to their industry or market. For example, an industry leader, a multinational, a regulated or a start-up business or one that has a history of contravening the law each could have different needs when establishing and implementing a credible and effective program. (Ethics in Community Association Operations, 2006)
Businesses today are faced with a daunting task of developing, implementing, and enforcing a compliance program. This is a difficult area because what works at one industry will not be an effective approach at a different type of industry. So, where does one begin that has been hired as the person to direct the course to take which will result in a lengthy document laden with endless requirements which must be met by each employee; from the top to the bottom. Without the full cooperation of everyone in the company this document is pages full of empty declarations. The new task at the forefront of a modern business in this decade will be the development of a system which everyone associated with the company will buy into the new vision.
In order to achieve such a goal one will benefit from investigating some previous businesses history of developing a compliance program. "For the past century, American corporate regulation has consisted of periodic, dramatic regulatory interventions by federal law makers after a major scandal, together with more nuanced ongoing regulation by the states." (Biegelman, 2008) Now, we will take a look at some of the companies which have been a party to some of the major scandals.
First, we will begin with Enron a company which was formed in 1985 by Kenneth Lay after merging Houston Natural Gas and InterNorth. More than a few years later, when Jeffrey Skilling was hired, he developed a staff of executives that, through the use of accounting loopholes, special purpose entities, and poor financial reporting, were able to hide billions in debt from failed deals and projects. Enron's stock price, which hit a high of US $90 per share in mid-2000, caused shareholders to lose nearly $11 billion when it plummeted to less than $1 by the end of November 2001. (Enron Fraud, 2001) How can a company's value decline by such a catastrophic amount when in the eyes of Wall Street this was an American dream company?
With this in mind we should dig further to see if the company in fact had a set of business compliance and ethical standards for the business. Enron did have a 64 page code of ethics which was distributed to each employee. The opening statement of the booklet states the following "As officers and employees of Enron Corp., its subsidiaries, and its affiliated companies, are responsible for conducting the business affairs of the companies in accordance with all applicable laws and in a moral and honest manner" (Enron's "Code of Ethics", 2006) A company needs to have more than a document which is not followed by the leaders of a company. Were the actions of the ENRON CEO an acceptable practice of good ethics? The actions of the Enron executives painted a picture of what can happen when ethics are neglected. If the leaders had followed the ethical and compliance guidelines of their own company code of ethics, there would not have been a scandal. Their code of ethics is no more than a pamphlet of empty statements.
Second, Long Distance Discount Services, Inc. (LDDS) began in Hattiesburg, Mississippi in 1983. In 1985 LDDS selected Bernard Ebbers to be its CEO. The company went public in 1989 through a merger with Advantage Companies Inc. The company name was changed to LDDS WorldCom in 1995, and later just WorldCom. The company achieved its growth primarily through acquisitions during the 1990,s and reached its high point with the acquisition of MCI in 1998. The company was achieving excellent reviews and as a result the stock value grew. However, in the year 2000, the telecommunications industry entered a downturn and WorldCom's aggressive growth strategy suffered a serious setback when it was forced by the US Justice Department to abandon its proposed merger with Sprint in mid 2000. With WorldCom's stock declining and Ebbers came under increasing pressure from banks to cover margin calls on his WorldCom stock which was used to finance his other businesses. To aide Ebbers in meeting his margin calls the board provided him corporate loans and guarantees in excess of $400 million to cover his margin calls. The board felt this would avert additional downward pressure on the stock's price. Unfortunately, the plan failed and the board ended up ousting Ebbers as CEO in April 2002 and replaced him with John Sidgmore, former CEO of UUNet Technologies, Inc. (MCI,Inc)
"Beginning modestly in mid-year 1999 and continuing at an accelerated pace through May 2002, the company (under the direction of Ebbers, Scott Sullivan (.CFO), David Myers (Comptroller) and Buford "Buddy" Yates (Director of General Accounting)) used fraudulent accounting methods to mask its declining earnings by painting a false picture of financial growth and profitability to prop up the price of WorldCom's stock." (MCI,Inc) The fraud was achieved in primarily two ways:
Underreporting 'line costs' (interconnection expenses with other telecommunication companies) by capitalizing these costs on the balance sheet rather than properly expensing them. (MCI,Inc)
Inflating revenues with bogus accounting entries from "corporate unallocated revenue accounts" (MCI,Inc)
Once again, we need to investigate further and locate the intended business practices which the company would like to run the business by on a day-to-day basis. One would like to believe the original intent of the corporation would be to operate within the framework and guidelines of a reputable business. WorldCom was a large conglomerate of many acquired businesses by a very aggressive management team. Poor integration of acquired companies also resulted in numerous organizational problems. Among them were:
Senior management made little effort to develop a cooperative mindset among the various units of WorldCom. (MCI,Inc)
Inter-unit struggles were allowed to undermine the development of a unified service delivery network. (MCI,Inc)
WorldCom closed three important MCI technical service centers that contributed to network maintenance only to open twelve different centers that, in the words of one engineer, were duplicate and inefficient. (MCI,Inc)
Competitive local exchange carriers (Clercs) were another managerial nightmare. WorldCom purchased a large number of these to provide local service. According to one executive, "(t)he WorldCom model was a vast wasteland of Clercs, and all capacity was expensive and very underutilized There was far too much redundancy, and we paid far too much to get it. (MCI,Inc)
The appearance from the integration of the companies is that not enough emphasis has been placed on the code of ethics or code of conduct. "Ethics is defined as a system of moral principles and the rules of conduct with respect to a particular group or organization. There is a difference between a code of ethics and a code of conduct. The conduct code describes precautions on how one must behave. The ethical code describes statements of core values that indicate how one should behave. Ethics is about choice. Without choice, you have law rather than ethics. A person who is ethical acts with fairness, equity and impartiality and respects the rights of other people. Someone who is unethical chooses personal or professional gain at the expense of others. Most of us are somewhere in the middle, trying to do the right thing, sometimes unaware that we've done the wrong thing, and often surprised to find ourselves facing an ethical dilemma." (Ethics in Community Association Operations, 2006)
Finally, we will take a look at Toyota which has had to deal with numerous recalls of a number of vehicles in different models. When I hear the name Toyota I equate their brand with quality. What methods and standards of operations does the company have in place to ensure the continuous production of a quality vehicle and maintenance of their reputation? Toyota is very devoted to uphold a high level of ethics and compliance to standards. "For Toyota, compliance does not mean simply observing laws; it means respecting societal norms and corporate ethics, complying with the expectations of diverse stakeholders, and engaging in fair corporate activities." (Corporate Responsibilty, 2010) Here are some of the guiding principles at Toyota:
Honor the language and spirit of the law of every nation and undertake open and fair corporate activities to be a good corporate citizen of the world. (Corporate Responsibilty, 2010)
Respect the culture and customs of every nation and contribute to economic and social development through corporate activities in the communities. (Corporate Responsibilty, 2010)
Dedicate ourselves to providing clean and safe products and to enhancing the quality of life everywhere through all our activities. (Corporate Responsibilty, 2010)
Create and develop advanced technologies and provide outstanding products and services that fulfill the needs of customers worldwide. (Corporate Responsibilty, 2010)
Foster a corporate culture that enhances individual creativity and teamwork value, while honoring mutual trust and respect between labor and management. (Corporate Responsibilty, 2010)
Pursue growth in harmony with the global community through innovative management. (Corporate Responsibilty, 2010)
Work with business partners in research and creation to achieve stable, long-term growth and mutual benefits, while keeping ourselves open to new partnerships. (Corporate Responsibilty, 2010)
This has been a trying time for Toyota due to a number of accidents involving their vehicles. The top management of the company has expressed their heartfelt apologies for the recent events. Akio Toyoda, President of Toyota Motor Corporation went on to state "My objective is not simply to achieve growth in terms of expanding Toyota's size: My aim is to maintain sustainable growth by ensuring that all Toyota employees are committed to paying the utmost attention to each and every vehicle that is produced as we endeavor to deliver safe and high-quality cars at affordable prices to people the world over." (Corporate Responsibilty, 2010)
Certainly, there has to be a business in place today which is operating successfully while meeting acceptable ethical standards. I have been a fan of Warren Buffet, born August 30, 1930, an American investor, industrialist, and philanthropist. Often called the "legendary investor Warren Buffett", he is the primary shareholder, chairman and CEO of Berkshire Hathaway. Berkshire Hathaway is a conglomerate holding company headquartered in Omaha, Nebraska, United States that oversees and manages a number of subsidiary companies. Berkshire has averaged an annual growth in book value of 20.3% to its shareholders for the last 44 years, while employing large amounts of capital, and minimal debt. (Berkshire Hathaway, 2010) How does this conglomerate achieve such massive numbers and do it while maintaining ethical standards?
In this case the company is very proud of the values with which it conducts business.
It has and will continue to uphold the highest levels of business ethics and personal integrity in all types of transactions and interactions. To this end, this Code of Business Conduct and Ethics serves to:
(1) Emphasize the Company's commitment to ethics and compliance with the law (Berkshire Hathaway, 2010)
(2) Set forth basic standards of ethical and legal behavior (Berkshire Hathaway, 2010)
(3) Provide reporting mechanisms for known or suspected ethical or legal violations (Berkshire Hathaway, 2010)
(4) Help prevent and detect wrongdoing. (Berkshire Hathaway, 2010)
This company has a commitment from the top which goes a long way in living up to a high standard. Warren Buffet has a rule of thumb:
"â€¦I want employees to ask themselves whether they are willing to have any contemplated act appear the next day on the front page of their local paper - to be read by their spouses, children and friends - with the reporting done by an informed and critical reporter." (Code of Business Ethics)
With this in mind most of us would act in a manner which would avoid having ourselves or family exposed to the headlines due to our involvement in unethical conduct in the line of business. The code of ethics of Berkshire Hathaway is a mere 5 pages in length. The difference between this document and that of other major companies comes down to leadership. It is extremely important for a company to be lead by a strong leader committed to excellence. The bottom line is important in order to keep the doors open. It is not necessary to conduct business operations in a manner which is against the law. On the positive side most companies do abide by the rules and regulations set forth in the company handbook. Likewise the business needs to place an emphasis on how business is conducted on a daily basis. For example, the ethical standards of Berkshire reference (1) Conflict of Interest, (2) Corporate Opportunities, (3) Fair Dealing, (4) Insider Trading , (5) Confidentiality, (6) Protection and Proper Use of Company Assets, (7) Compliance with Laws, Rules and Regulations, (8) Timely and Truthful Public Disclosure, (9) . Significant Accounting Deficiencies. (Code of Business Ethics)
Additionally we would benefit by looking closely at Berkshire Hathaway's business ethics.
Conflicts of Interest A conflict of interest exists when a person's private interest interferes in any way with the interests of the Company (Berkshire Hathaway, 2010)
Corporate Opportunities Covered Parties are prohibited from taking for themselves opportunities that are discovered through the use of corporate property, information or position without the consent of the Board of Directors of the Company. No Covered Party may use corporate property, information or position for improper personal gain and no employee may compete with the Company directly or indirectly. Covered Parties owe a duty to the Company to advance its legitimate interests whenever possible. (Berkshire Hathaway, 2010)
Fair Dealing Covered Parties shall behave honestly and ethically at all times and with all people. They shall act in good faith, with due care, and shall engage only in fair and open competition, by treating ethically competitors, suppliers, customers, and colleagues. (Berkshire Hathaway, 2010)
Insider Trading Covered Parties who have access to confidential information are not permitted to use or share that information for stock trading purposes or for any other purpose except the conduct of the Company's business. (Berkshire Hathaway, 2010)
Confidentiality Covered Parties must maintain the confidentiality of confidential information entrusted to them, except when disclosure is authorized by an appropriate legal officer of the Company or required by laws or regulations. (Berkshire Hathaway, 2010)
Protection and Proper Use of Company Assets All Covered Parties should endeavor to protect the Company's assets and ensure their efficient use. (Berkshire Hathaway, 2010)
Compliance with Laws, Rules and Regulations Obeying the law, both in letter and in spirit, is the foundation on which the Company's ethical standards are built. In conducting the business of the Company, the Covered Parties shall comply with applicable governmental laws, rules and regulations at all levels of government in the United States and in any non-U.S. jurisdiction in which the Company does business. (Berkshire Hathaway, 2010)
Timely and Truthful Public Disclosure In reports and documents filed with or submitted to the Securities and Exchange Commission and other regulators by the Company, and in other public communications made by the Company, the Covered Parties involved in the preparation of such reports and documents (including those who are involved in the preparation of financial or other reports and the information included in such reports and documents) shall make disclosures that are full, fair, accurate, timely and understandable. Where applicable, these Covered Parties shall provide thorough and accurate financial and accounting data for inclusion in such disclosures. (Berkshire Hathaway, 2010)
Significant Accounting Deficiencies The CEO and each senior financial officer shall promptly bring to the attention of the Audit Committee any information he or she may have concerning (a) significant deficiencies in the design or operation of internal control over financial reporting which could adversely affect the Company's ability to record, process, summarize and report financial data or (b) any fraud, whether or not material, that involves management or other employees who have a significant role in the Company's financial reporting, disclosures or internal control over financial reporting. (Berkshire Hathaway, 2010)
As a rule, you would imagine the preferred approach for developing a compliance program for a business would be to duplicate the procedures followed by a successful company like Berkshire Hathaway. Regrettably this is not a viable approach due to the complexities associated with each type of business. As previously mentioned this is an overwhelming task and will require numerous tough choices which you will need to make for the company. With this in mind the first step is to choose what is needed in the plan to protect your business.
It is important to realize we need to be aware of the value and importance of implementing a voluntary corporate compliance program. Understand the core elements of a corporate compliance program. Know how to develop a solid foundation for a corporate compliance program. Why bother, so many corporations have written an excellent compliance program only to have the greediness of a key player in the operation of the company commit a number of fraudulent activities.
The overall intent of this paper is to present a view which suggests that how we reward employee needs to incorporate a new approach we start with likely objections to using incentives, and then discuss the reasons for including an incentive based approach. Currently we live in a society driven by requiring some form of bonus to perform a task outside their normal duties.. One only needs to have a family with some children to realize this is the reality today. Obviously this is not always the case but, more often than not this is the reality today. So, how do we get anyone to do the right thing without providing some type of incentive? All pay based systems provide some form of reward for extra performance by an employee. You will find objections to this methodology of incentives and rewards. We then analyze the different aspects of this question:
Next, we will look at some of the objections for an incentives based approach.
People should not be rewarded for doing their jobs (Murphy, 2009)
On the one hand companies have incentive systems which already reward people for doing their jobs. For example, sales personnel are supposed to sell, and they are frequently given commissions and other rewards for selling. CEO's receive excessive bonuses for meeting certain targets. Employees at all levels are compensated for doing their jobs and normally given more for doing more. This is the reality of our current system.
It is impossible to evaluate employee's virtue or ethics (Murphy, 2009)
The potential result of adopting a successful system to evaluate an employee's ethical values will go a long way in establishing a company you can be proud going to work for each day. One can only imagine the thoughts of the Enron employees which were subjected to the headlines in all of the media outlets every day. How does a parent explain the events to your children which look up to you for guidance and leadership? Personally, the importance of establishing and maintaining a strong ethics based program is worth the effort.
This is too subjective, unlike sales or production (Murphy, 2009)
The process will not be easy to accomplish but, a group should be able to develop a set of questions relevant to their industry which will provide a place to start. Any system will continuously require some adjustments over time. Most would have to agree some changes are necessary to meet the ever changing climate of the business community.
A number of current evaluations are based on judgmental elements;
c. Developing subordinates
d. Embracing change
e. Encouraging teamwork
f Communicating effectively
g. Team commitment
h. Treating co-workers with respect and dignity
i. Taking accountability for professional growth (Murphy, 2009)
This makes you question why the resistance to adding measuring performance in relation to the code of conduct. Just because this is a difficult task does not mean this is not a viable addition to the measure of performance. A measurement such as this may save the demise of future organizations. No economy can continue to allow the level of corruption which is a direct result of poor ethical behavior.
Seems clear from this, the task of building a world class compliance program is a daunting task. My belief it is important to include a code of conduct for the business which bases some measure of performance to upholding a high level of ethics. I have included a few of the concerns of a reward system tied to an item that is not measured by counting. Although, this is a method which is based on personal judgments there already exists performance measurements on a personal review which are based on judgments. There will continue to be discussions for and against the inclusion of rewards based on adherence to a company's code of conduct. It is important to have the discussion due to the importance of the topic.
On the positive side the US government is supportive of some type of incentive plan as part of a compliance program:
The US government's standards: the Sentencing Guidelines' 2004 amendments now make it clear that incentives must be part of a compliance program if it is to receive credit in sentencing.
"Providing appropriate incentives (for instance, compliance could be considered for the purposes of employee evaluations, promotions and bonuses) for performing in accordance with the compliance program can play an important role in fostering a culture of compliance. Incentives can work as effective tools for a business that wishes to promote compliance by employing concrete actions." (Corporate Responsibilty, 2010)
The ultimate goal for all parties is to aide in preventing misconduct and leading employees to act ethically and legally. To this point the late management expert, Peter Drucker, offers a succinct answer:
"Changing habits and behavior requires changing recognitions and rewards.People in organizations, we have known for a century, tend to act in response to being recognized and rewarded - everything else is preaching. . . . The moment they realize that the organization rewards for the right behavior they will accept it." (Murphy, 2009)
Additionally Stephen Cutler, Director, Division of Enforcement of the SEC in advising companies on how to set the right tone at the top:
"Make integrity, ethics and compliance part of the promotion, compensation and valuation processes as well. For at the end of the day, the most effective way to communicate that "doing the right thing" is a priority, is to reward it. Conversely, if employees are led to believe that, when it comes to compensation and career advancement, all that counts is short-term profitability, and that cutting ethical corners is an acceptable way of getting there, they'll perform to that measure. To cite an example from a different walk of life: a college football coach can be told that the graduation rates of his players are what matters, but he'll know differently if the sole focus of his contract extension talks or the decision to fire him is his win-loss record." (Murphy, 2009)
The concept is directly related to human nature. Individuals normally are more receptive when they receive some form of reward. All one needs to do is look at the bonuses CEO's receive today for meeting financial goals. What is going to happen when the government is requiring a form of incentive as a part of a company compliance program in order to receive credit in sentencing? As a result will there be a corresponding reduction in white collar crimes.
White collar crime is a term coined by Edward Sutherland for nonviolent crimes committed by corporations or individuals such as office workers or sales personnel in the course of their business activities. White-collar crimes include embezzlement, false advertising, bribery, unfair competition, tax evasion, and unfair labor practices. (Curtis, 2010)
Will the culture change dramatically by rewarding good behavior? Again, normally people tend to recognize what is getting rewarded at the company. It is easy for an employee to recognize what type of person is receiving the promotion and what type is regularly passed over for promotions. The old saying goes that nice guys finish last. It is important to realize that if employees with questionable ethics are rewarded and promoted the tone at the top and throughout the different levels of the organization will normally lead to similar behavior at each level of the company. On the positive side if those which adhere to compliance and ethics are selected as leaders and are seen by other employees as being rewarded and recognized, this will become the tone of the company from the top to the bottom.
In conjunction with this will require the inclusion of compliance and ethics performance in an employee's assessments and evaluations. Some examples of areas that could be measured:
Uses the code of conduct and encourages subordinates to do the same (Murphy, 2009)
Actively takes steps to implement the compliance program and the code of conduct (Murphy, 2009)
Attends appropriate compliance training, and makes sure subordinates get appropriate training and know the rules that apply for their jobs (Murphy, 2009)
Is willing to challenge questionable conduct or proposals (Murphy, 2009)
Seems clear we are experiencing a concerted effort which is moving towards creating a more responsible business climate. An increasing number of companies are incorporating ethics into their training. With all of the recent setbacks of some very prominent businesses it appears employees and CEO's understand what ethics are about, business can improve with sound ethical practices. Equally important the community will take note of the ethical nature of a business and so will customers.
In the last analysis most companies realize they need to develop and implement some type of business ethics and compliance program. Some areas to incorporate in the program:
Establish a code of conduct that reduces risk of criminal behavior (Anderson)
Demonstrate company's ethical/legal philosophy during an investigation (Anderson)
Reduce fines if company is found guilty of wrongdoing (Anderson)
Enhance company reputation and stature (Anderson)
Incorporate rewards for employee compliance. (Anderson)
Establish a procedure for a whistle blower. (Anderson)
Implement a business ethics training program. (Anderson)
For a new company a person may consider hiring an external consultant to assist in the process. Developing a program from scratch will be very time consuming and you may not have anyone with the skills required to write an effective plan. (Anderson)
"For a compliance and ethics program to be effective it needs to affect the behavior of those acting for the company. Rewards and incentives clearly do this, and need to be included in any program." (Murphy, 2009)
"In a practical world, compliance and ethics programs also must exist to help the company in times of crises when outside skeptics believe the company has done something wrong. A strong compliance and ethics program should demonstrate the company's good faith." (Murphy, 2009)
A very important aspect in achieving a successful ethics and compliance program is to involve the employees. Equally important will be to use some recognition letters for employees which have continually maintained high ethical standards. "A strong compliance and ethics program should demonstrate the company's good faith." (Murphy, 2009)
In the last analysis, what you incorporate in your ethics and compliance program will need to be aware of the laws and rules of the business. Along with implementing an incentives program which will go a long way in assisting in maintaining a successful ethics and compliance program. It is important to develop a program which demonstrates the company's appreciation of all of the great things the people in the organization do towards showing ethical leadership. I am hopeful that the generation of today will be supportive of change to a more compliant business. The development and subsequent implementation of a corporate world which will embrace the concept of rewarding good behavior at each level in the organization will be a move in the right direction.
The compliance team needs to decide which type of company they want to emulate. An Enron or WorldCom which were not trustworthy and have watched their stock value soar to the top only to fall to the bottom. An alternate choice will be to follow the lead of Warren Buffet. I will restate the Buffet philosophy,:
"â€¦I want employees to ask themselves whether they are willing to have any contemplated act appear the next day on the front page of their local paper - to be read by their spouses, children and friends - with the reporting done by an informed and critical reporter." (Code of Business Ethics)
What this demonstrates is that with support from the top your company will have a greater opportunity to achieve sustainable success. Who would you rather go to work for each day?
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Ethics in Community Association Operations. (2006, July). Retrieved August 7, 2010, from Association Times: http://www.associationtimes.com/articles2006/ethicsCAO
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Murphy, J. (2009). Building Incentives In Your Compliance & Ethics Program. 27.